Legal Opinion

Roberts v. Commissioner

United States Board of Tax Appeals

Decided September 20, 1928No. Docket No. 12248PublishedCited by 2 opinions

Under the facts of this case, held, that petitioner was not an "officer or employee" of the State of Georgia or political subdivision thereof, and that the compensation received by him, under certain contracts for the collection of delinquent taxes is not exempt from taxation under section 1211 of the Revenue Act of 1926.

1Opinion of the Court

*442OPINION.

TRAmmell:

The petitioner contends that the income here in controversy is exempt from tax under section 1211 of the Revenue Act of 1926, which provides as follows:

Sec. 1211. Any taxes imposed by the Revenue Act of 1924 or prior Revenue Acts upon any individual in respect of amounts received by him as compensation for personal services as an officer or employee of any State or political subdivision thereof (except to the extent that such compensation is paid by the United States Government directly or indirectly) shall, subject to the statutory period of limitations properly applicable…

2Cases cited4 opinions

  1. Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
  2. United States v. HartwellSupreme Court of the United States · 1868
  3. Hall v. WisconsinSupreme Court of the United States · 1880
  4. Kinsman v. Hartford Courant Co.Supreme Court of Connecticut · 1919

3Cited by2 opinions

  1. Pease v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Roberts v. CommissionerUnited States Board of Tax Appeals · 1928

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